The government repeatedly urges companies to implement compliance programs that can be expensive and time-consuming. Even as it continues to demand major fraud settlements, totaling more than US$4 billion in fiscal year 2011, from some companies, the government has indicated that it will treat companies differently when they are structured to operate in compliance with the law. In this article, Squire Sanders of counsel Thomas E. Zeno tells the story of a company that took the government at its word. Although the journey was not easy, the story has a happy ending.
This article was previously published in the Westlaw Journal Health Care Fraud, Vol. 18, Iss. 4. Reprinted with permission of the publisher.